We just started a NDIP side to our bank and i am trying to study up on all the regulations associated with it, so if this comes off as a dumb question, oh well. We will have the ABC Bank, ABC Invesment Services, and the third party that will be handling the accounts. Am i correct in thinking that ABC Investment Services will be an affiliate and the third party securities firm will be the non affiliated third party?

We have a similar set up, but our senior management indicated to me that our bank, not the holding company, owns the isurance company. Because of that, we treat it as part of the bank rather than an affiliate and the securities firm we sell through is a third party.


We are debating some issues regarding investments right now too. If anyone has any experiece with joint marketing agreements please let me know. I am trying to decide exactly what we need and if our existing contract with the third party constitutes a joint marketing agreement.